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2011 (3) TMI 1333 - HC - Income TaxExemption u/s 10A denied - acquisition of majority shares by the American company of which respondent was a subsidiary company - Held that:- The company itself was set up in the previous year relevant for the assessment year 2001-02 and therefore there can be no transfer of the assessee to foreign company because the respondent company was really a subsidiary company in India of the American company from the very beginning of relevant assessment year. We find force in the finding of the Tribunal that the denial of assessee's claim of exemption on the profit earned from the export of computer software under Section 80HHE on technicalities as untenable - Decided in favor of the assessee.
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